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Comments on the New Transfer Policy

  • To: <transfer-comments-a@xxxxxxxxx>
  • Subject: Comments on the New Transfer Policy
  • From: "Margie Milam" <Margie.Milam@xxxxxxxxxxxxxxx>
  • Date: Mon, 31 Jan 2005 16:58:10 -0700

Pursuant to ICANN's request, MarkMonitor, an ICANN-accredited registrar, is 
submitting its comments in connection with the new transfer policy.  Our 
general impression to date is that the transition has been positive with a 
majority of the registrars complying with the new procedures.  In addition, we 
have the following specific comments:


1.    Locked Names.  With the new transfer policies, it appears that a number 
of registrars have put their customer's domains on locked status.  This has 
created a burden on the gaining registrar since it is now incumbent on the 
gaining registrar to spend a significant amount of time assisting the new 
customer to understand how to unlock their domain names with the registrar of 
record.  If this problem persists, ICANN may need to consider standardizing the 
procedures to unlock a domain name.  In the meantime, it would be helpful if 
ICANN would gather and publish the unlock procedures for each registrar in 
order to assist gaining registrars in educating their customers.


2.    WHOIS information.   For those registrars that allow anonymous or private 
registrations, determining the identity of the registered name holder and/or 
administrative contact is sometimes difficult.  It would be helpful if ICANN 
would encourage registrars that offer anonymous/private registrations to 
specify their procedures for identifying the actual registrant.  


3.    Authorization Codes Procedures.  In some instances it can be difficult 
for registrants to obtain AuthInfo codes from their existing registrar.  If 
this problem persists, it may be preferable to have the AuthInfo request 
process standardized. In the alternative, it would be helpful if ICANN could 
gather and publish the procedures to obtain AuthInfo Codes from each registrar.


4.    Registrar's Compliance.  

*       While most registrars are complying with the new procedures, some 
transfer requests have resulted in the registrar of record imposing additional 
requirements not specified in the new policy, such as requiring the gaining 
registrar to immediately supply the FOA in response to each transfer request 
and "nacking" the transfer if it is not supplied. 
*       It has been Markmonitor's experience that several registrars do not 
send the required notices specifying the reasons for denying a transfer.   

5.    Form of Authorization.  A separate FOA should be adopted when the 
transfer involves both a simultaneous registrar/registrant transfer. This 
typically occurs when a party has purchased a domain name and/or has been 
awarded a domain name under a UDRP.   In this situation, the seller or 
transferor may not want to agree to the registration terms and conditions of 
the gaining registrar as it may not intend to have a future business 
relationship with the gaining registrar.


6.    Reseller Involvement.  Transfers involving resellers of a registrar are 
typically more difficult to accomplish because many resellers will list 
themselves as the administrative contact in a WHOIS record but may not respond 
to transfer requests in a timely manner. 


MarkMonitor is generally pleased with the cooperation of the registrars in the 
implementation of the new transfer policy.  To date, with few exceptions, the 
registrars we have contacted have made good faith attempts to comply with the 
new transfer rules.   




Margie Milam<?xml:namespace prefix = o ns = 
"urn:schemas-microsoft-com:office:office" />


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